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#2188192 - 08/06/18 09:01 PM Part-Time BSA Officer
Anonymous
Unregistered

I know many slightly smaller community banks have a Compliance Officer who doubles as a BSA Officer. However, I am curious to know at what asset size this might be considered a bad practice. For example, if a bank with just over $1 billion in assets downsizes their BSA department and now only has a part-time BSA Officer (who is also the Compliance Officer), and this results in a sudden, noticeable decrease in SAR filings, I feel this bank would possibly be criticized by examiners.

I would be interested to hear anyone's experiences with examiners regarding similar situations, or any opinions anyone might have. Thanks in advance!

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#2188195 - 08/06/18 09:45 PM Re: Part-Time BSA Officer Anonymous
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
Asset size alone isn't really enough to indicate what the appropriate BSA staff count is. Staffing would depend on the unique risk presented by a Bank's clients, products, services, etc. I've seen a one person BSA Department and BSA Departments with thousands of resources, both of which are staffed appropriately. It may be helpful to do a staffing analysis to support the downsizing you referenced.
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#2188215 - 08/07/18 01:29 PM Re: Part-Time BSA Officer Anonymous
osucpa Offline
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Joined: May 2011
Posts: 1,406
Agree with ACBbank. There are a lot of variables involved.

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#2188246 - 08/07/18 03:13 PM Re: Part-Time BSA Officer Anonymous
Anonymous
Unregistered

I am aware that asset size is not the only determining factor. That is why I pointed out that this change resulted in a noticeable decrease in SAR filings. It isn't like a growing bank suddenly stopped having suspicious activity. Also, this bank's risk assessment has determined that it has a moderate BSA risk which is slowly increasing, which makes the recent decrease in BSA staff slightly more baffling.

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#2188247 - 08/07/18 03:28 PM Re: Part-Time BSA Officer Anonymous
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,844
Pulling people out of the ditc...
just decreasing the number of SAR filings in itself is no cause for concern, especially if a large number of previous SARs were defensive filings or your bank has closed a number of accounts that previously had SAR activity. if you are in one of the BSA or Compliance rolls as a member of management, then you should bring your concerns to your manager. ask for clarification and direction. i can assure you that no one on this board can speak to the specifics of what your bank management is thinking or doing, and speculation just creates further issues. so, ask the questions.
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#2188306 - 08/07/18 07:35 PM Re: Part-Time BSA Officer Anonymous
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,199
The West
I agree with Happy Gilmore. My bank is approaching $10B and when I joined there were a lot of defensive filings. I advocated for account closures and stopped filing in some cases, so our SAR filings decreased dramatically.

The risk profile of the bank and other factors will determine if this can be reasonably managed. Also the skills of the BSA department employees.
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#2188330 - 08/07/18 08:45 PM Re: Part-Time BSA Officer Anonymous
Anonymous
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Another anon mentions, re: "It isn't like a growing bank suddenly stopped having suspicious activity. "

Just to continue that speculation: it didn't stop. It decreased. It definitely seems possible that, as trends change and criminals change and adapt, the filings at any one given institution may drop sharply, year over year.

While ABC Bank in Wyoming may see a drop in filings, those criminals may have shifted to XYZ Bank in Illinois, which would see an increase in filings. Neither of these arbitrary statistics tells you anything about either bank's BSA department.

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#2188698 - 08/10/18 02:52 PM Re: Part-Time BSA Officer Anonymous
Anonymous
Unregistered

Not Original Anon

There are a lot of variables, but I would think that at a certain asset size auditors/examiners would be surprised. The activity likely has not changed that drastically.

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